The primary causes of circular debt include:  Poor governance  Delays in tariff determination by an inadequately empowered regulator compounded by interference and delay in notification by the Government of Pakistan (GOP)  A fuel price methodology that delays infusion of cash to the power secto

1.
COMMISSIONED BY PLANNING COMMISSION
OF PAKISTAN
FUNDED BYTHE UNITED STATES AGENCY FOR
INTERNATIONAL DEVELOPMENT (USAID)
The Causes and
Impacts of Power Sector
Circular Debt in Pakistan
March 2013

2.
The Causes and
Impacts of Power Sector
Circular Debt in Pakistan
March 2013
COMMISSIONED BY THE PLANNING COMMISSION
OF PAKISTAN
FUNDED BY THE UNITED STATES AGENCY FOR
INTERNATIONAL DEVELOPMENT (USAID)
DISCLAIMER
The authors’ views expressed in this publication do not necessarily reflect the views of the United States Agency for
International Development or the United States Government

3.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN I
FOREWORD
Power sector inefficiencies have cost this country significantly in direct
budget costs in the last five years. In addition, growth has been slowed
down by at least 2% per annum i.e., 10% lost growth in the last five
years. Yet the problem is far from behind us.
The restructuring and reform of the power sector has been held up for
over two decades leading the costs to accelerate in recent years. The
important question that arises is “Why are we incapable of addressing
such a big problem.” The problem requires careful study and research
which can only happen if time and resources are devoted to the
problem. With enough independent expertise and research for
developing a body of knowledge on the required reform, a process of
reform must be developed in Pakistan. There have been major
shortcomings at all levels of the reform spectrum which are split into
three main areas:
 At the policy level there is complete disarray between all entities
involved. The Ministry of Water & Power, which is the main
policy maker of the sector has no roadmap set out for itself and is
more reactive than proactive to power sector reforms which of
course is coupled by a lack of political will to help improve the
system.
 At the regulatory level there is an authoritarian attitude towards all
entities involved. The regulator has failed to address or
acknowledge problems of the power sector and is working in
isolation.
 At the entities level there is a complete breakdown of governance.
Though they are being micromanaged by both the policy makers
and the regulator, the entities themselves have no aspirations of
moving ahead reforms and are happy to maintain status quo.
For the reform process to move forward there needs to be a concerted
effort from all involved. Roles should be clearly identified and roadmap
is set so that there is no ambiguity on the ultimate objective. The
roadmap must be designed in conjunction with the Framework for
Economic Growth (FEG) so that there is cohesion with all economic

4.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN II
goals. There has to be an element of sustainability and accountability in
the whole process. The FEG was based on extensive research and
consultation and approved by the National Economic Commission in
2011, has emphasized that if we want to achieve high growth the
emphasis in the coming period must be on the “software” (economic
reform, management and productivity improvements) rather than the
“hardware” (brick and mortar investments) of growth. The FEG argues
for mainstreaming reform especially that of public sector management,
regulatory improvements, and more competitive markets for innovation
and entrepreneurship.
This report, which USAID has prepared in collaboration with the
Planning Commission of Pakistan, is an attempt to identify the root
causes of the current circular debt and what steps needs to be taken to
not only reduce the debt but also continue with the reform process
moving ahead. In my view it is an urgent requirement and should be
widely discussed to see how this process can be made an urgent priority.
It informs the readers of the underlying causes and the way forward.
 Lack of creating a decentralized system of governance is at the
heart of the problem. Efficient power sector reform cannot be
pursued with this centralized system that is run by a ministry.
 Decentralized and independent entities must be run on corporate
lines with corporate management without government or
ministerial interference.
 Technology is part of the solution as it allows for improved
monitoring, measurement and payments.
 The decentralized system needs an able, competent, independent
and empowered regulator who is responsible and accountable for
the efficiency of the system and not just tariffs.
 The tariff system must be reviewed continuously to ensure that
due costs be passed on to consumers, elimination of cross
subsidies, timely fuel price adjustments and artificial loss
provisions.
 The question of uniform tariffs should be done away with through
careful planning and research.
 Subsidy if any should be targeted to the poor only and not as
currently available to all.

5.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN III
 With these improvements the system can be made solvent over a
period of time. Then investments will start flowing in not only for
increase of capacity but also for more efficiency including a better
fuel mix.
We have tried to identify the problem and find steps to its resolution. I
complement our teams at USAID and the Planning Commission on a
worthy study that does indeed delineate a road map to tackle the circular
debt issue.
But this is only one beginning. Unless this report is taken seriously and a
reform process built, we will continue to see this problem stretched out.
Dr. Nadeem Ul Haque
Deputy Chairman
Planning Commission
Government of Pakistan

6.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN IV
FOREWORD
I am pleased to present the Circular Debt Report, which the Planning
Commission of Pakistan has commissioned and the United States
Agency for International Development (USAID) has funded. The report
is based on an independent analysis. The challenges analyzed in this
report are not insurmountable. I am hopeful that the Government of
Pakistan and other stakeholders will find the report informative and that
even more important, they will use it to address the critical issues that
have led to deterioration of the power sector. The circular debt issue did
not arise over night, it has existed for a long time and our findings take
into consideration the stock of circular debt accumulated since 2006.
Although there are several factors contributing to this crippling circular
debt, improvements in energy sector governance, enabled by strong
political support, could resolve the problem and make the sector self-
sustainable.
Addressing the accumulation of circular debt will increase the financial
resources needed for the proper functioning of the energy sector. We
firmly believe that, with improved and expanded power delivery,
increased economic growth and improved socio-political stability will
follow.
Allow me to congratulate and thank the various experts and officials
from the Government of Pakistan who contributed to the data
collection and analysis for this comprehensive report. We at USAID
remain committed to supporting the government and people of Pakistan
in resolving the critical issues in the energy sector.
Jonathan Conly
Mission Director
USAID / PAKISTAN, ISLAMABAD

9.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN VII
MWP Ministry of Water and Power
NA Not Available
NAB National Accountability Bureau
NEPRA National Electric Power Regulatory Authority
NTDC National Transmission and Dispatch Company
PAC Public Accounts Committee
PAEC Pakistan Atomic Energy Commission
PDP USAID Power Distribution Program
PEPCO Pakistan Electric Power Company
PESCO Peshawar Electric Supply Company
PPA Power Purchase Agreement
QESCO Quetta Electric Supply Company
Rs Pakistani Rupee
SEPCO Sukkur Electric Power Company
T&D Transmission and Distribution
TDS Tariff Differential Subsidy
TESCO Tribal Areas Electric Supply Company
TOU Time of Use
WAPDA Water and Power Development Authority

10.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 1
EXECUTIVE SUMMARY
This report addresses the circular debt issue in relation to the Pakistan power sector.
Circular debt is the amount of cash shortfall within the Central Power Purchasing Agency
(CPPA) that it cannot pay to power supply companies. This shortfall is the result of (a) the
difference between the actual cost of providing electricity in relation to revenues realized by
the power distribution companies (DISCOs) from sales to customers plus subsidies1
; and (b)
insufficient payments by the DISCOs to CPPA out of realized revenue as they give priority to
their own cash flow needs. This revenue shortfall cascades through the entire energy supply
chain, from electricity generators to fuel suppliers, refiners, and producers; resulting in a
shortage of fuel supply to the public sector thermal generating companies (GENCOs), a
reduction in power generated by Independent Power Producers (IPPs), and an increases in
load shedding.
Circular debt at the end of Fiscal Year (FY) 2011 was estimated to be Rs537 billion. At the
end of FY 2012 it was estimated to be Rs872 billion2
representing approximately 4% of the
national nominal Gross Domestic Product (GDP). Circular debt, if continued unabated, will
increasingly constrain the availability of electricity and slow down economic growth.
The primary causes of circular debt include:
 Poor governance
 Delays in tariff determination by an inadequately empowered regulator compounded
by interference and delay in notification by the Government of Pakistan (GOP)
 A fuel price methodology that delays infusion of cash to the power sector
 Poor revenue collection by the DISCOs
 Delayed and incomplete payment by the Ministry of Finance (MOF) on Tariff
Differential Subsidy (TDS) and Karachi Electric Supply Company (KESC) contract
payments
 Prolonged stays on fuel price adjustments (FPAs) granted by the courts
 Transmission and distribution (T&D) losses and theft.
The federal government retains the authority for approving customer tariffs, but is influenced
by a legacy system that supported a single postage stamp rate for all consumers in each
category across all DISCOs. The GOP is not implementing the differential tariffs determined
by the regulator for each DISCO, which often overshadows commercial decision-making.
This results in conditions that contribute to circular debt, including a reluctance to pass on
1
This implies that Receivables = Payables to CPPA = circular debt in energy sector. This is somewhat an oversimplification as a small
portion of receivables may be net payables to non-energy suppliers. This refinement is not done here to avoid confusion in addressing the
circular debt issue.
2
Data collected by EPPfrom PEPCO & DISCO Performance Statistics Reports and Chief Engineer’s Office and by PDP from NEPRA and
MWP. Figure does not include amounts for circular debt that could not be verified at the time this report was prepared.

11.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 2
the full cost of electricity to customers; uniform tariffs do not take into consideration the
actual cost of service. Establishment of a TDS that is often not paid on time or in full and is
allocated primarily on the basis of “just-in-time” response to the power sector, overstaffing
and compromised decision making at the DISCOs, and the subsidies provided to tubewell
customers often result in lengthy disputes over payment between the DISCOs and provincial
governments.
The federal government also has been lax in passing appropriate legislation to curb
electricity thefts, promote energy conservation, increase commercial transparency,
strengthen regulatory entities, and promote an open and competitive energy market. The
government also appoints the Board of Directors (BOD) of the DISCOs; political and
bureaucratic influences continue to limit the BOD’s independence and technical and
management competency. At the corporate level, the Boards’ authority and efficacy in
monitoring and enforcing the performance of DISCO management is limited or nonexistent.
The National Electric Power Regulatory Authority’s (NEPRA) role also needs to be revisited
and its operations improved. The annual determination of tariffs for the DISCOs and
subsequent adjustments for fuel cost are lengthy and ineffective, resulting in revenue
shortfalls and cash flow problems and obscuring the true cost of electricity to consumers.
NEPRA also needs to improve its enforcement powers over the DISCOs with regard to
cases of consumer overbilling and requires additional authority to move ahead with
implementation.
There also are several secondary causes to circular debt, including:
 The need to improve the thermal efficiency of the GENCOs and for NEPRA to set
tariffs based on actual vs. estimated heat rates
 Inadequate budgeting of the TDS, which delays payment and increases financing
costs
 Unfavorable generation mix of the GENCOs, due largely to the GOP’s fuel allocation
policy that diverts natural gas to other non-economic uses
 Non-commercial/non-professional approach to load shedding; non-improvement in
tariff terms and conditions; impact of court decisions that have delayed payments to
the DISCOs
 Late payment surcharges (LPS) paid by CPPA to the IPPs resulting from the inability
of the DISCOs to fully pay CPPA; the GOP’s neglect in promoting demand-side
management, energy efficiency and renewable energy resources
 The need to settle payment arrears (both disputed and undisputed) in a
comprehensive manner; and the need for expanded authority of CPPA to collect
payments from the DISCOs through formal and enforceable power purchase
agreements (PPAs).

13.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 4
(2) Undertake specific policies and programs to improve the governance and performance of
energy sector entities to decrease costs, increase cash flow, and ensure
operational/financial integrity of the sector.
Recommendations to achieve this goal include:
ROLE OF GOVERNMENT
 The GOP needs to redefine its role in the power sector to one as a policy builder on
a national energy level and work through the BODs and allow international best
practices for improved corporate governance for each of its owned entities, with a
goal to allow corporatization for proven financially sound entities.
 The GOP needs to support a more competitive market structure and assist NEPRA
to be independent and strengthen the professional and technical requirements for
members and staff; and develop a comprehensive capacity building and training
effort initiated.
 Tariff and subsidy disputes between the provincial governments and CPPA and the
DISCOs, need to be resolved, either by negotiation or arbitration.
 Legislation declaring electricity theft a punishable crime with penalties ranging from
fines to imprisonment needs to be implemented with specialized courts established
for the purpose.
 The selection criteria and methodology for appointment of DISCOs’ BODs needs to
be improved. Members of the BODs need to have high professional and technical
capabilities; be independent of political influence; have full authority for decision-
making at the DISCO; and receive training to effectively monitor performance and
enforce accountability of DISCO management and staff. Changes to Articles of
Association of the DISCO to improve director’s term of office and maintain
institutional knowledge with proper rotation and replacement.
 Eliminate the uniform tariff and gradually move toward the regulator’s differential
tariffs based on true costs. The regulator to enhance tariffs with targeted
performance-based tariff to all DISCOs and remove to current cross subsidy between
the efficient and inefficient DISCOs.
 Improve the fuel allocation policy in the short-term to allocate fuel to the highest
value uses (e.g., assign a high priority to power sector in the allocation of natural
gas), and in the long term eliminate fuel allocation so that fuel use is based on
competitive market forces.
 Formulate policies and plans to promote hydro power and other domestic sources of
energy that will assist in balancing the electricity supply portfolio.
 Implement a strong program of energy conservation and demand-side management.

14.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 5
REGULATORY LEVEL
 The system of annual tariff determination for all companies (DISCOs, National
Transmission and Dispatch Company (NTDC), and GENCOs)), needs to be
reformed. NEPRA should institute a system of multi-year tariffs, which will allow time
to focus on other regulatory functions.
 There is a considerable time delay in determination and implementation of the fuel
adjustment charge. NEPRA should adopt a system of prospective fuel prices in tariff
determination and make corrective adjustments on a timelier basis.
 Aggressively monitor the performance of power companies to enforce compliance
with their license conditions.
 Tariff structure and the conditions of supply (terms and conditions of tariff) need to be
revised in light of the present market practices.
CORPORATE LEVEL
 The DISCOs do not operate on a commercial basis and are unduly subject to political
influence. The DISCOs should be corporatized and the process managed by a
reputable international consulting firm.
 Institute a system of fuel testing and prevention of fuel theft for each GENCO.
 Implement a comprehensive energy loss reduction program at each DISCO focusing
on reducing technical losses to permissible technical operating limits depending on
available investment, and reducing non-technical losses, initially to NEPRA’s given
targets.
 Design and implement programs focused on energy efficiency and demand-side
management.
 Enforce electricity supply contracts, disconnecting defaulting customers without
discrimination.
 Implement a comprehensive revenue collection and theft prevention program at each
DISCO, with elements including, but not limited to: replacing electromechanical
meters with modern metering technology and digital automated meter reading
systems (AMR) systems; and reform business processes to improve management
control and customer service.
 Introduction of empowerment and accountability, reward and reprimand at all levels.
 Time of Use (TOU) tariff be aggressively pursued with clear marked difference
between the peak and off-peak rates based on the nature of use. Peak and off-peaks
be defined on the basis of optimal usage in addition to the system peak hours.

15.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 6
Figure 1: Stock of Circular Debt as of June
2012
Figure 2: Causes of Circular Debt

16.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 7
1. INTRODUCTION
1.1. CIRCULAR DEBT AND CONTEXT OF THE PROBLEM
This report addresses the circular debt issue in relation to the Pakistan power sector. The
term “circular debt” is used somewhat differently by various entities in Pakistan.4
In essence,
the term “circular debt” is understood to be the amount of cash shortfall within the CPPA,
which it cannot pay to power supply companies. This short fall is the result of (a) the
difference between the actual cost of providing electricity and the revenue realized by the
DISCOs from sales to customers, plus subsidies;5
and (b) insufficient payments by DISCOs
to CPPA out of the revenue realized since they give priority to their own cash flow needs.
According to estimates, the circular debt at the end of FY 2012 was Rs872.416
billion,
representing approximately 4% of the national nominal GDP.
The DISCOs’ inability to make full payments to the CPPA results in cash flow problems,
which cascade through the energy supply chain. The result is a shortage of fuel supply to
generating companies, a diminished power generation capacity and limited investment to
maintain the entire system. Reduced capacity to generate and supply power coupled with
previously existing supply/demand gaps and frequent breakdowns in the infrastructure have
resulted in extensive load shedding across the country.
During the summer months of FY 2012, urban areas were subjected to – on average – eight
hours of load shedding per day while some rural areas exceeded 16 hours per day. The
prolonged power cuts and load shedding resulted in country-wide civil disturbances.
Load shedding has adversely affected the economy and disrupted social life in the country. It
is estimated that in 2008, load shedding in the industrial sector cost the country over Rs210
billion, over $1 billion from export earnings and a potential displacement of 400,000
workers.7
The adverse impact of load shedding is much higher if the impact on the agriculture
and services sectors is included.
1.2. CAUSES OF CIRCULAR DEBT
Deficiencies of governance at the government, corporate, and sector level are at the heart of
the circular debt issue. At the government level, these can be attributed to political
interference, short- sighted and defective policies (or lack thereof), under-budgeting of TDS,
and non-settlement of intra- and inter-government issues. The government has also failed to
pass legislation to curb theft and promote energy conservation as well as protect diligent
functionaries. At the corporate level, poor governance and the ineffectiveness of the DISCO
BODs in guiding and monitoring company performance is a major problem. In addition,
continuation of legacy management with almost no professional approach and having no
4
State Bank of Pakistan Annual report 2010-2011, Pakistan Economic Survey 2011-12, NEPRA.State of Industry Report – 2011.
5
This implies that Receivables = Payables to CPPA = circular debt in energy sector. This is somewhat of an oversimplification as a small
portion of receivables may be net payables to non-energy suppliers. This refinement is not done here to avoid confusion in addressing the
circular debt issue.
6
Data collected by EPP from PEPCO & DISCO Performance Statistics Reports and Chief Engineer’s Office and by PDP from NEPRA and
MWP. Figure does not include amounts for circular debt that could not be verified at the time this report was prepared.
7
“State of the Economy: Emerging from the Crisis,” Panel of Economists, Beacon House National University, Lahore. 2009.

19.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 10
2. PRIMARY CAUSES OF
CIRCULAR DEBT
Although there are many contributing factors to circular debt, there are five primary drivers.
These include poor sector governance; delays in tariff determination and notification; delays
in FPA notification; poor revenue recovery from government and private consumers; and
excessive T&D losses. This chapter addresses each of the primary causes, noting where
failures have occurred and what actions can be taken to address the issues.
2.1. GOVERNANCE
Poor governance is at the heart of the issue of circular debt. Governance needs to improve
at all levels, i.e. government, corporate, and regulatory.
2.1.1. GOVERNANCE AT THE FEDERAL AND PROVINCIAL GOVERNMENT
LEVEL
The federal government is both the majority owner as well as a large customer of the power
sector. As owner, it retains the prerogative of ultimate decision-making regarding customer
tariffs. Unfortunately, as a political entity, the government is influenced by both political and
socio-economic considerations. These often overshadow commercial decision-making, and
result in a reluctance to pass on the full cost of electricity to customers. Other political and
external factors typically result in interference in DISCO operation, including overstaffing,
compromise of merit-based staff performance, lack of transparency in procurement,
uneconomic investments, etc.
At the provincial level, governments generally are not proactive in the resolution of issues
such as the reconciliation of electricity bills, payment of tubewell subsidies arrears, arrears of
provincial departments, and arrears due to court orders. In addition, the failure to accept
responsibility for the problems stemming from the allocation of power shortages to different
provinces continues. If, for example, the issue of bill reconciliation with the Sindh
government, the gap created by the Balochistan governments’ lack of responsibility for
payment of tubewell subsidies, the arrears of Rs19.79 billion9
in the Province of Khyber
Pakhtunkhwa (KPK), and the tariff rate issue for Azad Jammu & Kashmir (AJK) were
resolved, a significant portion of circular debt could be substantially reduced.
The federal government has the responsibility to develop the legal framework for the sector,
for example, with respect to electricity theft and overall sector governance. However, it has
not been adequately attended to comprehensive legislation needed to improve governance
and reduce electricity and fuel theft. For example, a legal remedy is needed to protect
DISCOs from revenue loss due to the courts’ stay orders, preventing them from enforcing
supply agreements when they disconnect defaulting customers or in cases where a
consumer is caught stealing electricity.
9
Source: PEPCO DISCOs Performance Statistics Reports 2012.

20.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 11
The government also is responsible for appointing power companies’ BODs, providing them
with policy guidelines, and monitoring their performance. However, political and bureaucratic
influences continue to hamper the government’s performance in this regard. This results in
reduced competence and lack of independence of Board members and poor management
and operational performance of the DISCOs. Likewise the government embarked on the
process of appointment of professional Chief Executive Officers (CEOs) of the DISCO about
a year back. However, in spite the fact that the entire process has since been completed,
except for Peshawar Electric Supply Company (PESCO), no other company has a CEO
appointed through the selection process.
A key function of the federal government is the formation and implementation of national
energy policy. In this regard, the GOP needs to develop a comprehensive policy for effective
governance of the power sector, including reducing the number of GOP entities involved in
the sector, which often have overlapping or ill-defined authority and often lack the capacity to
effectively perform their designated functions. For example, a lack of political consensus on
hydropower development and generation planning has led to increased dependence on
imported fuel or furnace oil and, as a result, an unbalanced power generation mix that has
necessitated customer subsidies. As subsidies are not allocated appropriately, benefits
extend to those beyond the targeted customer sector. The financial, accounting, and data
systems related to the Ministry of Water and Power (MWP) and MOF subsidies are not well-
managed and require significant improvement.
Moreover, the government-provided fuel subsidy has led to the direct government allocation
of fuel among consuming sectors of the economy, thus further distorting energy markets and
contributing to shortages of fuel to generate power and to the circular debt problem.
Allocations are mainly based on political considerations rather than on economic benefits. In
the short term, the GOP needs to allocate fuel to the various sectors of the economy based
on the highest value to the economy. In the long term, fuel prices need to more accurately
reflect market prices and to be allocated throughout the economy based on competitive
market principles. In addition, GOP support for development of domestic energy sources,
such as hydro and other renewable energy resources and natural gas, would help to reduce
dependence on imported fuel.
Federal and provincial governments are responsible for NEPRA appointments. Yet by
amending or misinterpreting the NEPRA Act’s appointment provisions, unqualified persons
have been appointed to NEPRA. The GOP also needs to augment NEPRA’s authority to
move from the present single buyer model for the power sector to a multiple buyer/seller
model. In addition, reform initiatives such as privatization of the DISCOs need to be
accelerated and completed in a timely manner. In brief, the GOP’s failure to create and
maintain an enabling environment for the efficient operation of companies and the effective
regulation of the sector has led to many of the problems impacting circular debt.
2.1.2. INADEQUATE CORPORATE GOVERNANCE
Governance at the company level leaves much to be desired. For the most part, the
DISCOs’ BODs do not have sufficient authority or capacity to demand accountability of
management and staff and are ineffective in managing DISCO performance. Politically-
driven appointments of CEOs and top management continue to prolong and enhance self-

21.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 12
interest groups in maintaining the status quo. The USAID Power Distribution Program (PDP)
has recommended many areas for improving corporate governance which have been made
through USAID-supported programs, but these have yet to be properly
implemented.10
Similarly, USAID has provided strategic recommendations for GENCOs in
addressing critical problems such as fuel theft, fuel adulterations, and poor corporate
management and performance. These have been incorporated in comprehensive business
plans, and await implementation.
Customer Service rules are not enforced and do not adequately reward good customer
performance or discourage poor performance. At times, companies have deliberately over-
billed customers, yet were able to escape meaningful punishment. It has been alleged that
power and fuel thefts are often conducted with employee collusion. The result is a culture
that ignores theft on the part of some workers and poor performance on the part of others
and does not reward those who try to perform their functions honestly and with high
professional ethics. A Customer Service manual and other performance documents
prescribed by NEPRA set out parameters of service. However, none of the DISCOs adhere
to such parameters, nor does NEPRA seem to have the will to do so.
2.1.3. GOVERNANCE BY NEPRA
NEPRA was established in 1997, and is legally responsible for the regulation of Pakistan’s
power sector. It is legally an independent, quasi-judicial authority and, since its inception,
has formulated licensing rules, performance standards, grid codes, eligibility criteria, power
procurement regulation, procedures for tariff determinations, and other standards and codes.
NEPRA has succeeded in improving operation of the power sector as compared to the time
when the sector was bureaucratically controlled. However, much still needs to be corrected,
particularly in relation to tariff-setting. The procedure for tariff determination is lengthy,
resulting in tariffs that are non-compensating by the time they are put in force. Similarly,
NEPRA’s administration of fuel price adjustment charges is ex post facto with a significant
time delay, thereby failing to cover the rising fuel costs for the power producers resulting in a
distorted price signal to customers.
NEPRA members are nominated by the provinces and appointed by the federal government.
While professional standing of appointees is one of the qualifications for appointment,
nominations are driven by various personal and political considerations. Consequently,
NEPRA is subject to pressure from political and executive quarters in the performance of its
functions and generally lacks the professional competency needed to effectively perform its
regulatory functions. Moreover, NEPRA’s inability to move beyond the single buyer model in
which CPPA is the sole purchaser of power from the power producers and sole seller to the
DISCOs needs to be strengthened. This lack of ability inhibits movement towards a
competitive power market where power producers and customers are empowered to make
direct arrangements to buy and sell electricity on a competitive basis.
The regulator is short of qualified technical staff and has to increasingly depend on contract
and seconded government staff, which often creates a conflict of interest. A review of the
numbers and composition of its staff and subsequent realignment to ensure that staffing
10
USAID Power Distribution Program: DISCO Operational Audit Reports and Performance Improvement Action Plans issued in 2010.

22.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 13
matches the needed capability should be done. In addition, the perks and benefits structure
for the staff at NEPRA also needs to be reviewed. NEPRA could not retain the professionals
it has had as they eventually moved on, having been offered better packages elsewhere in
the country.
NEPRA also lacks effectiveness in enforcing accountability of the DISCOs, particularly with
respect to reducing T&D loss levels, and meeting performance standards and license
conditions as set out through the investments allowed through the tariff petitions filed and
performance targets set. In addition, the public does not clearly understand the regulator’s
role and rationale, resulting in consumers’ confusion and unrealistic expectations.
2.2. DELAYS IN TARIFF DETERMINATION AND NOTIFICATIONS
Delays in tariff determination and notification contributed Rs72.19 billion11
to the circular debt
for FY 2012. Tariff determinations for all nine DISCOs were delayed for nine months and it
took an additional month for the notification to be published. Consumer tariffs in 2011-12
were largely based on 2010-11 tariff values whereas the actual fuel cost for 2012 was 52%
higher than the previous year. Without new tariff values from NEPRA and the GOP, the
DISCOs had no chance to receive the necessary cash required to meet their monthly
wholesale power cost.
Once NEPRA determines the tariff, the GOP reviews it and officially notifies a tariff after
modifications as deemed appropriate. Although NEPRA has reduced the time it takes to
determine tariffs, the determination procedure still takes many months. In addition, tariff-
setting lacks independence, as the GOP notification process often results in a delay and/or
reduction in the tariff due to political considerations.
2.3. FUEL PRICE ADJUSTMENTS
Delays in NEPRA’s application of the FPA mechanism contributed Rs33.19 billon12
to the
circular debt in 2012.13
The FPA is a mechanism through which monthly variations in fuel
costs, as compared with the reference amount determined in the NEPRA tariff, are passed
on to the end user. The FPA mechanism adds to circular debt during periods of rising fuel
costs by delaying this adjustment value by two to six months. This creates a cash shortage
for the power producers for energy already delivered.
The current FPA method is to bill consumers after the fact using historical cost and an
annual reference amount as opposed to using projected fuel consumption and cost. This
leads to fuel adjustments that swing radically each month and creates consumer unrest. The
current method does not include a process for looking ahead as global fuel price conditions
change or the country’s fuel mix ratios differ from the reference values.
2.4. POOR REVENUE COLLECTION
Poor revenue collection contributed Rs86.9 billon to the circular debt in 2012. Five of the
DISCOs had good collection rates while the other four (Hyderabad Electric Supply Company
11
PDP Analysis based on NEPRA determination of DISCOs’tariffs 2012.
12
Source: PDP Analysis based on data from Tariff Cell -Ministry of Water & Power.
13
Note: The delay in charging of FPA has been calculated as the difference between what should have been charged to consumers as FPA
vs. what is actually charged.

23.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 14
– HESCO, Sukkur Electric Power Company – SEPCO, Peshawar Electric Supply Company
– PESCO, and Quetta Electric Supply Company – QESCO) contributed Rs72.14 billon or
83% of the total uncollected amount. Poor revenue collection is due to a number of factors,
as described below.
2.4.1. POOR COLLECTION FROM PRIVATE CONSUMERS
Non-payment of electricity dues by private consumers is one of the largest contributors to
circular debt. The problem is not uniform across the country as some DISCOs have good
track records while others display poor collection efficiency. Of the Rs197 billion14
receivables from private consumers at the end of FY 2012, 73% is attributable to PESCO
(including Tribal Areas Electric Supply Company (TESCO)), HESCO (including SEPCO),
and QESCO. The position of each company is shown in Table 3.
Table 3: Private Receivables – Million Rs.15
DISCOs 2008-09 2009-10 2010-11 2011-12 % Share
PESCO* 26,809 32,902 41,282 51,360 26%
HESCO 18,856 25,454 33,344 44,237 22%
QESCO 4,297 5,238 24,780 48,193 24%
LESCO 10,957 15,968 17,081 23,080 12%
GEPCO 3,585 5,322 5,631 5,912 3%
FESCO 3,719 5,676 5,866 7,068 4%
IESCO 2,287 2,286 2,762 2,703 1%
MEPCO 7,252 10,505 11,900 14,638 7%
All DISCOs 77,762 103,351 142,646 197,191 100%
* PESCO Includes TESCO and HESCO Includes SEPCO
In terms of annual performance in the collection of revenue, the overall efficiency was 87%16
in FY 2012. The financial impact of not recovering the remaining 13% is estimated to be
around Rs86 billion, or equal to 41 days of furnace oil costs for thermal power plants.17
Again, PESCO, HESCO, SEPCO, and QESCO had the worst collection efficiency, as shown
in Table 4.
14
Source: PEPCO DISCOs Performance Statistics Reports 2012.
15
Source: PEPCO DISCOs Performance Statistics Reports 2008 – 2012.
16
This figure includes Rs 7.0 billion released by the Ministry of Finance as a subsidy for FATA.
17
This has been calculated taking Rs70, 000 as furnace oil price per metric ton and factoring in the total requirement of these plants as
30,000 metric ton per day.

24.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 15
Table 4: DISCO Wise Revenue Collection Efficiency
DISCOs 2007-08 2008-09 2009-10 2010-11 2011-12
PESCO* 71% 67% 227% 78% 68%
HESCO 77% 68% 60% 59% 60%
QESCO 86% 80% 76% 41% 36%
LESCO 98% 96% 93% 98% 96%
GEPCO 98% 95% 96% 99% 98%
FESCO 99% 97% 97% 100% 98%
IESCO 98% 97% 96% 93% 96%
MEPCO 97% 96% 94% 98% 97%
All DISCOs 89% 92% 106% 89% 87%
* PESCO Includes TESCO and HESCO Includes SEPCO
Source: PEPCO DISCOs Performance Statistics Reports FY 2008-2012
The main factors contributing to the increase in receivables include the DISCOs’ lack of
accountability, political interference, failure to disconnect defaulting customers, lack of
modern technology for metering and revenue collection, and fear of reprisal from protesting
customers upon disconnection or replacement of meters. Moreover, the high tariff
(particularly with reference to the consumers’ ability to pay) is, in some cases, encouraging
collusion among consumers.
2.4.2. INSUFFICIENT PAYMENT BY PROVINCIAL GOVERNMENTSAND AZAD
JAMMU & KASHMIR GOVERNMENT
DISCOs supply electricity to various provincial government departments, schools, hospitals,
police stations, water and sewerage facilities, and offices, some of which are perpetual
defaulters. Reasons for inadequate payment vary from region to region and department to
department but, typically, defaulters attempt to justify non-payments on the following
grounds:
 Non-reconciliation of billing between the DISCO and the concerned government
department
 Shortage of funds due to insufficient budget allocations to concerned departments.
Despite the fact that DISCOs have a prescribed procedure for bill correction and
reconciliation, government departments tend not to follow these procedures and thereby
delay payments. Over the last few years, provincial and federal governments have been
unable to reconcile the figures for electricity bills due from provincial governments. DISCO
receivables from the provincial governments and AJK were Rs100.48 billion18
as of June 30,
2012, accounting for 11.5% of the total circular debt at the end of FY 2012.
18
PEPCO DISCOs Performance Statistics Reports 2012.

25.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 16
Table 5: DISCOs Receivables from Provinces & AJK – Millions Rs
Province 2005 2006 2007 2008 2009 2010 2011 2012
Punjab (481) (9) (381) 162 (7) 3,263 5,371 5,842
KPK 239 398 652 254 601 1,144 19,427 19,792
Balochistan 538 119 146 709 1,064 2,419 4,662 52,696
Sindh 341 2,382 3,224 7,603 14,241 25,790 39,230 6,200
AJ&K (50) 485 756 1,216 2,391 4,393 9,888 15,953
Total 587 3,375 4,397 9,944 18,290 37,009 78,578 100,483
Source: PEPCO DISCOs Performance Statistics Report (FY 2005- FY 2012)
2.4.3. INSUFFICIENT PAYMENT BY FEDERAL GOVERNMENT, FATA & AGRI-
TUBEWELLS
Receivables from the federal government represent unpaid bills of federal government
departments, government-owned corporations, and autonomous bodies, as well as
subsidies for Federally Administered Tribal Areas (FATA) consumers and Balochistan tube
well consumers. Federal government receivables on these accounts stand at Rs30.1 billion
as at June 30, 2012.19
FATA is one of the least developed part of Pakistan, with limited industrial and commercial
activity, and high unemployment. Its location on the Afghan border makes it important,
especially in relation to the war on terror. Collection of billed electricity in FATA has
historically been a challenge due to the extreme poverty and palatable attitude of the
government towards the tribal areas.
2.5. INSUFFICIENT PAYMENT OF TARIFF DIFFERENTIAL
SUBSIDY BY THE MINISTRY OF FINANCE
The TDS reflects the government’s policy of applying a uniform tariff across all the DISCOs.
The GOP’s annual budgeted line item for this subsidy totaled Rs50 billon20
for FY 2012,
while the DISCOs claims for the same period amount to Rs156 billion.21
The outstanding
balance of the TDS to be paid by the MOF was Rs106.02 billion22
at the end of 2012, which
adds to the circular debt.
NEPRA determines the electricity tariffs based on the revenue requirement of each DISCO
to meet all costs and to earn a suitable profit. There is significant difference in the tariffs for
each category of customer and across the various DISCOs. The government has the power
to notify either the differential tariff determined by NEPRA or a modified (lesser) tariff, with
the government assuming payment of the difference. This is known as the TDS. The
underlying concept is that the DISCO must ultimately receive revenue as allowed by
NEPRA, either from the customers or with the support of a state subsidy. Since the
government has adopted a policy of uniform tariff across the country (generally the minimum
rate for each category of customer applied for by any of the nine DISCOs), the TDS owed by
19
PEPCO DISCOs Performance Statistics Reports 2012. (Receivables = Federal Govt + FATA + agricultural tube wells (GOP share))
20
Ministry of Water & Power, Chief Engineer’s Office.
21
Ibid.
22
Ibid.

26.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 17
the GOP on an annual basis is substantial. In addition, the government, historically, has not
provided the required TDS in a timely manner.
The MOF is responsible for paying the TDS to CPPA on behalf of the DISCOs. CPPA, then
credits the DISCOs’ accounts against the amount they owe to CPPA. The MOF has
provided an amount of Rs1.290 trillion23
to cover the TDS from 2006-07 through 2011-12 to
CPPA. This amount includes a loan of Rs312 billion24
that was made to the DISCOs to cover
their costs, which has been made a part of Pakistan’s national debt. This loan was obtained
by the DISCOs to pay their power purchase cost to CPPA, as the government did not fully
provide the required amount of subsidy to the DISCOs for the prior years. The adjustment of
this amount (i.e. Rs312 billion) against the subsidy claims of the DISCOs has yet to be
made. Therefore, CPPA has not yet provided the details of how the total amount of the
Rs1.29 trillion payment has been credited to the accounts of the DISCOs. This is mainly held
up due to a lack of information on how the amount of this TDS is to be adjusted for the
Rs312 billion loan, which has now been picked up by the GOP.
The MOF has recently decided to have the subsidy claims of the DISCOs verified through a
chartered accountant firm, which will further delay resolution of this issue. The MOF has
submitted a request to USAID to arrange the services of a chartered accountant firm for this
purpose. Once this task is completed, the CPPA will have a clear picture of the adjustments
to each DISCO’s account resulting from the Rs1.29 trillion TDS provided by the MOF. To
avoid this type of discrepancy in the future, the MOF should be responsible for monitoring
the amount of TDS that has accumulated for each DISCO and report its findings to the GOP
on an annual basis.
The concept of a uniform tariff regime needs to be objectively revisited. Because of legal
constraints, no consumer can be charged at a higher rate than that determined by NEPRA.
Therefore, for each consumer category, the GOP arrives at a uniform tariff based on the
lowest tariff determined by NEPRA for any DISCO. This results in a subsidy based on
political considerations rather than on need. A more targeted subsidy aimed at low-income
consumers and applied to a base level of consumption needs to be established. This would
target the subsidy to where it is needed most and would likely reduce the total amount of the
subsidy, as those with higher income or higher consumption levels would be excluded. As a
first step, the four top performing DISCOs (i.e. IESCO, FESCO, GEPCO, and LESCO)
should be allowed to explore corporate privatization to remove them from the uniform tariff
base. Once achieved, this would significantly reduce the circular debt.
2.6. IMPACT OF HIGH TRANSMISSION AND DISTRIBUTION
LOSSES
DISCO T&D losses for FY 2012 contributed Rs22.78 billion25
to the circular debt. NEPRA
determines distribution marginsbased on targeted T&D losses set for each DISCO.
However, many DISCOs fail to achieve these targets as shown in Table 7. In Pakistan,
approximately 50% of aggregate distribution losses26
reported by DISCOs are non-technical,
23
Ministry of Finance.
24
Ibid.
25
PDP Analysis of T&D losses based on data from PEPCO DISCOs Performance Statistics Reports 2012.
26
This is an aggregation that based on PDP operational audit reports technical loss assessments of all DISCOs.

27.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 18
with such underlying reasons as administrative problems, billing, theft, and pilferage of
energy. Excess losses result in less than NEPRA-determined revenues for the DISCOs, as
less energy is provided to end-use customers. This results in an increase in circular debt, as
presented in Figure 3.
PDP evaluated the DISCOs’ T&D losses through operational audits completed in 2010.
PDP-assessed technical losses among the DISCOs ranged between 8% and 15%,
identifying a potential opportunity for performance improvement through investments in
network upgrades, installation of state-of-the-art metering systems such as AMRs, low
tension (LT) capacitors, and other technical measures. Reducing average T&D losses for all
the DISCOs by 1% in FY 2011 would have resulted in savings of over Rs7 billion27
in power
purchase costs, and would have provided enough power to serve an additional 2.6 million
residential consumers, and reduced load shedding by 110 MW.
Ideally, if Lahore Electric Supply Company (LESCO), Gujranwala Electric Power Company
(GEPCO), Faisalabad Electric Supply Company (FESCO), and Islamabad Electric Supply
Company (IESCO) keep their losses below 10% while Multan Electric Power Company
(MEPCO), PESCO, HESCO (including SEPCO), and QESCO bring down their T&D losses
to 15%, DISCOs revenue would increase by approximately Rs50 billion from the following
DISCOs as shown in the table 6 below:
Figure 6: Increases in DISCO Revenue
Billion Rs. LESCO GEPCO FESCO MEPCO PESCO HESCO QESCO TOTAL
5 1 1 5 20 15 3 50
This reduction in losses can release 78428
MW of power generating capacity with a value of
Rs75 billion (which is equivalent to investing in the same amount of new generation
capacity), as well as aid in the reduction of load shedding. Even if they had complied with
NEPRA’s FY 2012 targets for T&D losses, DISCOs revenues would have improved by
approximately Rs22 billion. In the long-term, T&D losses need to be brought into alignment
with international standards of about 7% of total generation. Doing so would reduce system
losses by about 10.3 billion kilowatt-hours and save about Rs75.3 billion. In addition to this,
the losses are unrealistically reduced through parking of units or overbilling. This results in
creation of unrecoverable receivable’s or billing disputes and results in eventually lowering of
average sale rate.
27
Calculation of Savings due to1% loss reduction:
MkWh
Received
MkWh
Billed
Actual
Loss
% Actual
Loss
% Target
Loss
MkWh
Saved
Av. Sale
Rate
Rs/kWh
Savings
Million Rs
82,319 66,213 16,106 19.6% 18.6% 1,011 7.28 7,359
28
Ibid.

29.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 20
Table 8: High Transmission Losses32
2009 2010 2011 2012
NTDC
Actual 3.6% 3.1% 2.9% 2.8%
NEPRA Allowed 2.5% 2.5% 2.5% 2.5%
2.7. INSUFFICENT PAYMENT BY THE KARACHI ELECTRIC
SUPPLY COMPANY
KESC receives between 650 MW to 700 MW of power from NTDC/CPPA per day. However,
KESC had not been making full payments for the electricity it receives. KESC argues that its
electricity payments made to CPPA should be settled against the arrears of TDS from the
GOP. KESC and CPPA signed a PPA in January 2010, according to which KESC was
required to open a stand-by letter of credit with a commercial bank in favor of the CPPA to
the extent of their monthly power purchase cost minus TDS for the same month. The
contract is currently under review by the National Accountability Bureau (NAB) at the request
of MWP, due to the fact that the monthly TDS values exceed the cost of power purchased by
KESC. However, this agreement is not being implemented and KESC’s receivables as of the
end FY 2012 amounted to Rs54.7 billion33
of circular debt.
32
Source: Actual: PEPCO Power Distribution DISCOs Performance Statistics. NEPRA Allowed: NEPRA determination from NEPRA
Website.
33
PEPCO DISCOs Performance Statistics Reports 2012.

30.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 21
3. SECONDARY CAUSES OF
CIRCULAR DEBT
Secondary causes are those which indirectly contribute to the circular debt. These include
thermal inefficiencies of the GENCOs; inadequate budgeting of subsidies; unfavorable
generation mix; impact of court decisions on payments to the DISCOs; LPS; neglect of
demand-side management, energy efficiency and renewable energy; legacy payments; and
payables to CPPA for power purchased. Each of these is addressed below.
3.1. THERMAL INEFFICIENCIES OF GENERATION COMPANIES
GENCO tariffs are based on the heat rates of generating units. The heat rate is defined as
the amount of fuel consumed for each unit (kWh) generated. Over time, as efficiencies of
generating units have declined, heat rates have increased. The higher the heat rate of the
plant, the greater the amount of fuel consumed per unit of electricity generated. There are
some allegations of fuel thefts at the GENCOS, which also results in lower efficiency.
However, for tariff determination, NEPRA uses lower heat rates versus the actual GENCO
rates as shown in Table 934
. Consequently, the price of power delivered by the GENCOs is
underestimated as it does not reflect the true cost of fuel to the GENCOs. This reduces the
GENCOs’ income, resulting in cash flow difficulties, which causes the GENCOs to postpone
maintenance and other essential expenses, including payment to fuel suppliers. A heat rate
audit needs to be conducted to establish new benchmark heat rates for NEPRA to use for
tariff determinations. Until this audit is conducted, NEPRA cannot update its heat rate figures
for use in setting tariffs for the DISCOs.
Table 9: GENCO Heat Rate Comparison
GENCOs NEPRA Actual
CPGCL (GENCO I)
Block 1 8,533 9,153
Block 2 9,481 10,200
Block 3 11,377 13,109
Block 4 12,189 14,041
NPGCL (GENCO III)
Unit 1-3 (TPS Muzaffargarh) 10,788 11,677
Unit 4 (TPS Muzaffargarh) 10,692 11,087
Unit 5-6 (TPS Muzaffargarh) 12,158 14,164
Units 1-2 (SPS Faisalabad) 14,368 14,156
Units 1-4 (GTPS Faisalabad) 15,366 17,708
Units 5-9 (GTPS (Faisalabad) 11,701 10,259
Unit 1-3 (Multan) 14,114 16,169
JPCL (GENCO II)
Unit 1 (Jamshoro) 10,655 11,505
Units 2-4 (Jamshoro) 10,862 12,930
Unit 1-2 (Kotri) 21,813 22,353
Units 3-7 (Kotri) 10,564 11,902
34
Table 7 provides heat rate information for three GENCOs. The fourth GENCO, Lakhra,is small, with an operational capacity of 37MW
and operates intermittently.

31.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 22
Fuel theft and fuel adulteration has been recognized now as a common problem at the
GENCOS, which also results in lower efficiency. Due to lack of adequate fuel quality
assessment tools at the GENCOs, any adulteration of fuel received by GENCOs by fuel
providers cannot be detected. In addition, poor fuel storage and handling facilities further
deteriorate fuel quality, resulting in lower fuel efficiency and deterioration of plant machinery.
USAID’s Energy Policy Program has conducted a survey of fuel management and handling
capacity at the GENCOs. In 2010-2011, total fuel costs of the GENCOs amounted to Rs124
billion35
which account for 94%36
of the operating budget of the GENCOs, comparatively, fuel
management costs amount to less than 1% of the operating costs.37
3.2. INADEQUATE BUDGETING OF SUBSIDIES
The TDS historically has been under-budgeted. The federal budgeting process relies on
planning assumptions presented by various executing agencies. These assumptions pertain
to improved performance parameters, such as reduced losses, greater collections, and
increased tariffs. Based on these projections, the MOF budgets federal spending on power
sector subsidies. In practice, the planning assumptions are generally found to be overly
optimistic. As per MWP records, in FY 2012, the budgeted amount for TDS was Rs50 billion,
while the amount disbursed over the year was Rs156 billion (see Figure 6). Financing of the
unplanned subsidies takes time and adds an interest charge to the amount financed, further
adding to the circular debt.38
Figure 6: Tariff Differential Subsidy Budgeted, Claimed & Disbursed
Source: Ministry of Water & Power, Chief Engineer’s Office .
35
Financial Statements of NPGCL, CPGCL, JPGCL (2010-2011)
36
Ibid
37
Ibid
38
The interest due to delayed payment has not been included in Table 1 for want of reliable data.
87 82
-
30
5051.0
122.0
227.0
287.0
156.6
87 82 92
238
99
-
50
100
150
200
250
300
350
2008 2009 2010 2011 2012
Rs.Billions
TDS Budgeted Total Claims Subsidy Released

32.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 23
3.3. IMPACT OF UNFAVORABLE GENERATION MIX AND HIGH
GENERATION COST
One of the primary reasons for high tariffs in Pakistan is the unfavorable generation fuel mix.
Due to delay in exploitation of hydro power potential in the country, a number of private
sector oil-based IPPs were added to the system in 1994 and 2002. While these IPPs
provided much-needed new power generation capacity at the time, the country’s generation
mix tilted heavily towards Fuel Oil/Furnace Oil (FO). The GOP’s policy to divert gas to other
sectors of the economy, such as domestic consumers, and to encourage use of compressed
natural gas (CNG) for private vehicles further limits gas supply to the power sector, forcing
thermal generators to depend on more expensive fuels. Gas shortages further pushed
thermal generation towards more expensive fuels. Over time, the price of imported FO
increased substantially, inflating the cost of generation. This increase in cost was not passed
on to consumers and the gap between the GOP-notified tariffs and NEPRA-determined
tariffs increased, adding to the tariff differential subsidies required to be paid to the DISCOs.
The increasing subsidy burden is one of the primary reasons for fiscal constraints facing the
GOP in paying the TDS in a timely manner. The international price increase of FO occurred
in Pakistan at a time when the rupee was depreciating, making FO even more expensive,
thus driving up the cost of generating power.
As international oil prices are denominated in US dollars, the cost of imported FO increases
as the Pakistani rupee devalues against the dollar. From 2005 to 2011, the cost of FO
increased in real terms from $236 per ton to $639 per ton.39
At the same time, the Pakistani
rupee depreciated against the dollar such that the cost of imported FO rose from Rs21,087
per ton to over Rs70,93040
per ton (Figure 7). As a result, the cost of power generated from
FO grew 236% in six years.
Figure 7: Price of Imported Furnace Oil41
39
Source: Pakistan Energy Year Book 2011
40
Ibid.
41
Source: Various editions of Pakistan Energy Yearbook.
0
10000
20000
30000
40000
50000
60000
70000
80000
2004 2005 2006 2007 2008 2009 2010 2011
Rs/Ton
Price of Imported Oil Constant Rs/$

33.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 24
The increase in the cost of furnace oil coupled with the increase in the share of oil-based
generation from 16% in 2005 to 37% in FY 2012 (Figure 8) resulted in the high cost of power
purchased by CPPA.
Figure 8: Generation Mix42
Its impact on circular debt depends upon how soon and how much of the price increase is
passed on to, and eventually collected from customers. As explained in Section 2 above,
delays in NEPRA’s application of the FPA contributed more than Rs33 billion to the circular
debt in 2012 as the fuel price increase was not passed on promptly to customers, and
whenever it was, it resulted in only partial recovery of cost.
3.4. IMPACT OF COURT DECISIONS
Another factor that contributes to circular debt is that some customers or entities manage to
withhold the payments to DISCOs due to “stay orders” obtained through the courts. The total
financial impact in such cases has been substantial. For example, in 2008 the KPK
Government filed a petition against a tariff increase. Despite the fact that it later withdrew the
case, PESCO was not able to recover Rs18.6 billion43
from KPK consumers for the billing
period from September 5, 2008 to September 15, 2010 (accrued while the court’s stay order
was in effect) even after four years. HESCO faced a similar situation, when the Sindh
Government filed a suit against HESCO before the Sindh High Court and managed to block
HESCO from receiving payments from the Sindh Government for an extended period. It
should be noted that the courts should not be hearing these complaints when NEPRA has
made these determinations and allowed for a public hearing process, again showing the
weakness of the regulator.
3.5. LATE PAYMENT SURCHARGES FOR INDEPENDENT POWER
PRODUCERS
CPPA purchases power from various power generators and sells it to the DISCOs according
to the wholesale tariff rates determined by NEPRA. Due to the inability of the DISCOs to fully
42
NEPRA State of the Industry Report 2005, and NEPRA’s Determination for IESCO 2012.
43
PEPCO DISCOs Performance Statistics Reports 2012.
16%
52%
31%
0%
1%
FY 2005
Oil Gas Hydel Coal Nuclear & Imported
37%
26%
31%
0%
6%
FY 2012
Oil Gas Hydel Coal Nuclear & Imported

34.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 25
pay for the cost of power, and due to delays in payment of TDS, CPPA is in many cases
unable to make timely payments to the IPPs. As a result, CPPA bears the supplemental cost
of paying a LPS44
to IPPs as per the PPAS signed between CPPA and the IPPs. However,
NEPRA has not allowed CPPA to recover this cost due to the absence of an appropriate
sales purchase agreement between CPPA and the DISCOs. CPPA needs to complete and
put into force a formal and enforceable PPAs with the IPPs. The estimated annual financial
impact of the LPS over the past three years is estimated at Rs10-15 billion.45
3.6. NEGLECT OF DEMAND-SIDE MANAGEMENT, ENERGY
EFFICIENCY AND RENEWABLE ENERGY
Starting in the late 1970s, governments in many developing countries began promoting
demand-side management, conservation, energy efficiency and renewable energy
initiatives. With assistance from USAID, Pakistan began efforts to address these issues in
the mid-1980s with the creation of the National Energy Conservation Centre (ENERCON).
However, little effort to promote renewable energy was made until 2003. NEPRA has also
not devised a tariff suited to the specific characteristics of renewable energy development.
Demand-side management and conservation also continue to be neglected. The DISCOs
are in the business of selling power and collecting revenue and traditionally have not been
motivated to engage in demand-side management unless required by regulators.
3.7. LEGACY PAYMENTS
An analysis of circular debt and its components shows that the total debt increased from
Rs84.07 billion as of June 30, 2005 to Rs872.41 billion as of June 30, 2012.46
Calculated circular debt has two distinct components – disputed and undisputed arrears –
which need to be dealt with separately.
Disputed arrears are due to disputes related to billing between the DISCO and the provincial
governments (particularly Sindh), and disputes over tariff rates in the case of AJK. In the
past, efforts were made to settle the billing issue by deducting the amount of arrears from
the release of funds to the provinces from the Consolidated Fund (budgets). However, this
drew objections from the provinces who claimed that such deductions violated the
constitution and argued that the DISCO’s billing was inaccurate. In the late nineties, an
arbitrator was appointed to settle the issue between the DISCO and Sindh province. But
these efforts did not put the matter to rest and, following the 18th Amendment to the
Constitution, “at-source” deduction by the Federal Government is now considered
unconstitutional.
The undisputed component simply reflects consumers’ inability to pay the bills. Over the
years, shortfalls in the provision of subsidies by the federal and provincial governments, or
the non-settlement of receivable from KESC against TDS, have added to this debt category.
Some arrears are kept on the books because of the decision of the Peshawar and Sindh
44
At a rate of the Karachi Interbank Offered Rate (+3-4%), additional data being obtained.
45
Source: EPPanalysis.
46
See Sources for Table 1.

35.
THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 26
High Courts: Although the Sindh High Court ruled that the Sindh Government must pay all
bills from February 2010 forward, the Sindh Government has yet to fully comply.
Moving forward, the arrears issue needs to be settled in a realistic manner. Separate
approaches for disputed and un-disputed amounts need to be adopted, and all concerned
stakeholders given a deadline to clear past arrears. In the future, any default on amounts
owed should be dealt with strictly in accordance with the contract terms and conditions for
the supply of electricity. As regards the disputed arrears, in the short run, arbitral tribunals –
whose award must be final and binding – can be established. In the longer term, various
options, such as the installation of smart meters, prepaid meters or a system of joint or
community metering are possible. As this matter is between the provinces and the DISCO,
the federal government needs to avoid any temptation to intervene. The law should be
allowed to take its course for future defaulters.
Concerning the issue of rates with AJK, a federal government policy decision is needed
regarding the rate to be charged to AJK, and NEPRA needs to accept that rate. Similarly, if
the federal government owes TDS to KESC, then it may use the TDS to settle the KESC’s
arrears to the CPPA.
3.8. PAYABLES TO THE CENTRAL POWER PURCHASING
AGENCY FOR POWER PURCHASED
CPPA, which currently is part of NTDC, purchases power from generators on behalf of the
DISCOs. It then is responsible for making payments to the generators by billing and
collecting the cost of power delivered every month to each DISCO. Currently, CPPA’s power
sales to the DISCOs are not secured, since formal PPAs between CPPA and the DISCOs
do not exist. CPPA needs to complete and put into force formal and enforceable PPAs with
the DISCOs.
Payables to CPPA for power sold to the DISCOs are the result of the cumulative effect of the
primary and secondary causes of the circular debt discussed above, and the fact that
DISCOs give priority to meeting their own expenses from revenue collected, passing on only
the residual amount to CPPA. This residual amount is less than the cost of power recovered
and billed by the DISCOs.
The current trend of the DISCOs’ insufficient payments to CPPA is intensified by the
increased cost of generation in FY 2012, resulting from rising fuel prices. NEPRA allowed
power generators to bill CPPA for fuel adjustment charges incurred in FY 2011, but the
DISCOs were directed to recover the FY 2011 fuel adjustment charges in FY 2012, resulting
in a mismatch in costs incurred and revenue collected.
This current situation of increasing DISCOs payables to CPPA will not improve unless CPPA
is made autonomous and is covered by guarantees for full payment for the cost of power it
purchases on behalf of the DISCOs. This, in turn, will require that all the primary and
secondary causes of circular debt are addressed.

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THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 27
4. CONCLUSIONS AND
RECOMMENDATIONS
4.1. CONCLUSIONS
Four of the five primary causes of circular debt are due to a lack of good governance and the
inability of government/sectorial entities to effectively lay down policies/procedures and then
enforce them. Government agencies often implement their current procedures and
methodologies without considering their impact on circular debt. Capacity building of these
entities must be the main priority to ensure improved governance at benchmarked
standards. Tariffs must be in line with the current price of fuel and any time delay in tariff
determination and notification can cause huge cash shortage to the sector.
The current fuel cost reference and adjustment mechanisms need to be revamped to include
a forward vision approach for fuel cost recovery. Although the DISCOs’ revenue collection
will not improve overnight, NEPRA needs to give those DISCOs that have a program in
place to improve collections an “allowance for doubtful accounts” in their tariff determination.
This will raise their base tariff (schedule I47
) and create a delta between schedule I and
schedule II48
that would become part of the TDS. System losses are also largely
concentrated within the four poor-performing DISCOs. Implementing a purchase power
agreement between the DISCO and CPPA will legitimize this expense for the regulator and
allow it to be included in their tariff determination.
Most importantly, there is a failure of governance at all levels – federal and provincial
government, corporate entities and the regulator. The federal government has failed to
resolve the issues that would resolve the current circular debt problem and stop future
accumulation of the debt. The government has been reluctant to initiate improvements in the
legal framework to curb theft of electricity, limit the recourse to courts for debtors, and stop
political interference in sector governance. The system of indirect subsidy payments by the
MWP and MOF (including verification process, and data management of invoices and
payment of subsidies) all require improvement. Development of domestic energy resources,
including renewables, demand-side management and conservation continues to be
neglected. Provincial governments also are not proactive in resolving issues such as the
reconciliation of bills, tubewell subsidies, arrears of provincial government departments, and
arrears due to court orders.
At the corporate level, the efficacy of the BODs in monitoring and enforcing management
performance and accountability is lacking. Many areas of improvements of corporate
governance have been recommended through USAID assistance programs, but these have
yet to be implemented.
NEPRA’s role also needs to be improved. The annual determination of tariff and subsequent
adjustments for fuel costs is a lengthy process which currently creates revenue shortfalls.
47
NEPRA determined tariff.
48
GOP notified tariff.

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THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 28
Similarly, the delays in fuel cost adjustments not only cause cash flow problems but confuse
customers as to the true cost of electricity. NEPRA’s responsibility for protecting customer
interest also needs improvement. Overbilling is still an issue at DISCO level with NEPRA
only playing a reactive role.
The problem of circular debt is not insurmountable if the sector’s governance is improved.
Legacy payments can be wiped out through decisions/reconciliation of bills, arrears can be
reduced to the number of days of billing cycle through strict compliance with electricity
agreements, and TDS can be curtailed by charging the cost of supply of electricity to end-
users and targeting subsidies to deserving customers. Specific recommendations are given
in the following section.
4.2. RECOMMENDATIONS
The primary tasks before the GOP are to remove the current overhang of circular debt on
the power sector, and to prevent its recurrence. The current level of debt prevents
government owned entities from obtaining funding to support improvement in management
and system operations and from attracting investment needed to support sector expansion
and improved services. Major sector reforms and improvements in governance are needed
to prevent its recurrence.
To resolve these problems, the GOP needs to achieve two tasks:
(1) Remove the circular debt from the books of energy sector entities (DISCOs, CPPA) and
take responsibility for the mismanagement of the power sector reform process. Move the
circular debt amount to the government’s debt, reallocate in consumers tariff or place a tax
on the consumer to recovery over time
(2) Undertake specific policies and programs to improve the governance and performance of
energy sector entities to decrease costs, increase cash flow, and ensure
operational/financial integrity of the sector.
The high level of TDS requires the GOP to commit a substantial amount of budgetary funds
from scarce resources while reducing allocations for many other competing demands.
Prudence demands that various avenues be explored to reduce TDS to make it as
manageable as possible. This requires both short-term and long-term reforms at the
GOP/Policy, ministry, regulatory, DISCO/corporate and functional levels. Specific reforms
include the following:
4.2.1 ROLE OF GOVERNMENT
The GOP needs to ensure effective management and operation of the power sector as well
as its long-term financial viability. To do so, it needs to redefine its role in the sector from
primarily acting as owner/operator, to policy formation and sector oversight. There needs to
be a policy shift from Government to Governance. Accomplishing this role shift is a long-
term prospect, but needs to begin immediately through development and implementation of
the reform efforts outlined above. It also requires a covenant with the people of Pakistan and
with energy sector stakeholders to achieve real reform of the sector for the betterment of all.
It is important to keep in mind that the power sector reform effort is a comprehensive
program that affects all segments of the power sector, with short-term and long-term

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THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 29
objectives. Effectiveness of the program requires a comprehensive GOP strategy so that the
specific reform elements move forward together, as progress in one part of the sector (e.g.,
improved revenue collection by the DISCOs) requires progress in the other parts (e.g.,
legislation to make power theft a crime).
Specific reform elements at the GOP level include:
 NEPRA needs to be made truly independent; its authority to move from a single-
buyer to a more competitive market structure enhanced, the professional and
technical requirements for members and staff strengthened, its enforcement authority
increased, the composition of its technical staff reviewed and revised, and a
comprehensive capacity building and training effort initiated.
 Tariff and subsidy disputes between the provincial governments and CPPA and the
DISCOs need to be resolved, either by negotiations or arbitration.
 Legislation declaring electricity theft a punishable crime with penalties ranging from
fines to imprisonment. Special courts should be constituted to swiftly handle and
dispose of energy theft cases.
 The selection criteria and methodology for appointment of DISCO’ BODs needs to be
improved. Members of the BODs need to have high professional and technical
capabilities; be independent of political influence; have full authority for decision-
making at the DISCOs, and receive training to effectively monitor performance and
enforce accountability of DISCO management and staff.
 Eliminate the uniform tariff and gradually move towards differential tariffs based upon
true costs.
 Improve the fuel allocation policy in the short term to allocate fuel to the highest value
uses (e.g., assign a high priority to the power sector in the allocation of natural gas),
and in the long term eliminate fuel allocation so that fuel use is based on competitive
market forces. Allocation of cheap fuel should be on the basis of its larger economic
effect rather than political reasons.
 Formulate policies and plans to promote hydro power and other domestic sources of
energy that will assist in balancing the electricity supply portfolio.
 As gas resources are already depleting and hydro power needs considerable lead
time, and also since there is a significant availability of thermal based generation
capacity within the country, therefore there needs to be an urgency to implement coal
conversions at the available thermal power plants.
 Renewables as cheap fuel source with less dependency on imported fuel should be
considered a priority. The advantage with renewables power generation is that the
fuel spread is virtually all across the country and resultantly small to medium power
plants can be built at load centers with the added advantage of being environmental
friendly.

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THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 30
 Government/provincial government receivables to be paid as per other customers
and a mechanism of billing disputes to be reviewed within three months and no
option to file with the courts for the next five years.
 Implement a strong program of energy conservation and demand-side management.
4.2.2 REGULATORY LEVEL
 The system of annual tariff determination for all companies (DISCOs, NTDC, and
GENCOs), needs to be reformed. There are time delays in tariff filings and
determination, a lag in recovery of cost increases, and a mismatch between the
timing of tariff determinations for various segments of the sector. NEPRA should
institute a system of multi-year tariffs to overcome these issues and allow NEPRA
time to focus on other regulatory functions.
 There is a considerable time delay in determination and implementation of the fuel
adjustment charge. NEPRA should adopt a system of prospective fuel prices in tariff
determination and make correcting adjustments on a more timely basis.
 NEPRA needs to have the authority to gradually move from a single buyer model to a
multiple buyer/seller/open access model for the power sector.
 FPA mechanisms for DISCOs should be improved to eliminate the time lag for
determination and billing of FPA to customers.
 Aggressively monitor the performance of power companies to enforce compliance
with their license/tariff conditions/determinations.
 Tariffs and their terms and conditions need to be restructured.
 Out-of-the-box thinking for commercial governance. There are several commercial
governance models available in the utility businesses that have turned loss-making
entities into profit-earning ones.
4.2.3 CORPORATE LEVEL
 The DISCOs are owned by the government and therefore do not operate on a
commercial basis and are unduly subject to political influence. To overcome this
situation, the DISCOs should be corporatized and then privatized. Privatization is a
long-term goal, but policies and procedures to accomplish it need to begin now.
Transparency and openness in the privatization process is essential, and the
privatization process should be managed by a reputable international consulting firm.
 Each DISCO should be managed at corporate level by a professionally selected top
management. This team must be tasked with clearly defined JDs and KPIs. There
must be a clear corporate vision and demonstrated business plans for running the
DISCO.
 Top management must assign realistic targets with time lines to the operational
management. Such targets should be made a part of the annual performance
reviews (APRs) of the operation officers. The APRs should be a sliding scale and
should identify and reward good performers and reprimand non-/poorer performers.

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THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 31
 DISCOs should be given realistic targets for losses, recovery, quality, quantity, safety
and customer services.
 Implement a comprehensive energy loss reduction program in each DISCO,
especially in PESCO, HESCO, QESCO, and SEPCO where distribution losses are
relatively high. This program should focus on reducing technical losses to
permissible technical operating limits, depending on investment available, and
reducing non-technical losses initially to NEPRA’s given targets.
 Design and implement programs focused on energy efficiency and demand-side
management through tariff-charging appropriate to the usage.
 Enforce electricity supply contracts, disconnecting defaulting customers without
discrimination.
 Implement a comprehensive revenue collection and theft prevention program in each
DISCO, especially in HESCO, SEPCO, PESCO, and QESCO where revenue
collection is relatively low as compared to FESCO, GEPCO, LESCO, MEPCO, and
IESCO. Features of the program should include, but not limited to the, following:
– Replacement of electromechanical meters with modern metering technology and
digital AMR systems.
– Business processes reengineering to improve management control and customer
service.
 DISCOs must have improved visibility programs through better information
technology solutions like emails, improved database management, AMRs and real
time information of key commercial elements such as billing and recovery.
Technology is available in the market. It only needs to be brought in.
 Load shedding needs to be recognized and prioritized on a commercial basis across
all DISCOs. The benchmark should be 11KV feeder losses and recovery percentage.

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THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 32
APPENDIX A: TARIFFS IN
PAKISTAN
I. TARIFF SETTING PROCESS IN PAKISTAN
NEPRA was established by an Act of Parliament in 1997, and is legally responsible for the
regulation of generation, transmission, and distribution of electricity in Pakistan. It is legally
considered an independent, quasi-judicial authority. It has exclusive responsibility for
determining the DISCOs’ consumer-end tariffs, the tariff for the NTDC, and for all power
generation companies supplying electricity through the national grid or otherwise.
The Prime Minister of Pakistan appoints NEPRA’s chairman while one member represents
each province as part of the authority, thus completing the five-member decision-making
body. A pool of NEPRA employees that includes technical and financial professionals
supports the members. See NEPRA’s organization chart below.
Figure A-1: National Electric Power Regulatory Authority Organogram
Under Rule 6 of NEPRA’s Distribution Licensing Rules, only a distribution tariff approved by
NEPRA may be charged against a consumer, including bulk power consumers.

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THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 33
Clear rules for filing tariff petitions are included in NEPRA’s Tariff Standard and Procedures
Rules, 1998. A tariff petition should include:
 Name and address of petitioner
 Requisite fee
 Grounds for petition
 Relief or determination sought
 Comparative financial or other information for NEPRA review
 Comparative table of tariff design, proposed design, etc.
 Evidence of facts to support the petition
In cases where a license is issued and NEPRA has not determined a tariff, the Licensee has
90 days following the granting of the license to file a tariff petition. The procedure for making
a determination on a tariff petition is shown in Figure A-1. The process is described in more
detail below:
Figure A-2: Procedure for Tariff Determination
Registrar ascertains whether petition
is filed according to NEPRA rules.
Tariff Petition is filed with NEPRA (Registrar).
If Registrar is satisfied, the petition is submitted
to the Authority (Chairman + Members) for
formal admission.
Authority decides whether to admit
the petition for consideration; if
admitted, a
Case Officer is assigned.Hearing date is decided and notice of hearing
published in newspapers. Notices sent to
stakeholders. Comments/interventions
sought from any interested party.
A Public Hearing conducted by the
Authority. Case Officer sends an
“information direction” to petitioner.
Evidence closing date announced.
Decision, subsequent to any recalculation /
review/ reconsideration, communicated to
Cabinet Secretary for notification in the
Official Gazette.
Case Officer holds meetings with petitioner
and submits a report and recommendations
on the petition to the Authority.
Authority considers Case Officer’s
report and decides on the
recommendations. Authority issues its
determination within four months from
date of admission of petition; it may
extend this period for up to four more
months with valid reasons.Determination vetted by legal advisors.
Signed by Authority and issued. Copies
sent to all parties, to the petition.
Order part of determination sent to
Cabinet Secretary for notification. Any
concerned party has five days to file a
motion for recalculation and 10 days
to file a review motion. Government
of Pakistan has 15 days to ask for
reconsideration

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THE CAUSES AND IMPACTS OF POWER SECTOR CIRCULAR DEBT IN PAKISTAN 34
STEP 1: FILING TARIFF PETITION
All petitions are filed to the NEPRA Registrar. The registrar is responsible for determining
that the petition has been filed in accordance with NEPRA Tariff Rules and Regulations, has
been authorized by the Board of Directors of the filing company, and is duly accompanied by
the requisite fee.
STEP 2: ADMISSION OF PETITION
Once the Registrar has ascertained that the petition fulfills all legal and procedural
requirements for a petition’s filing, the petition is placed before NEPRA’s members and
Chairman for admission within 14 days of receipt. The Chairman and members are
collectively referred to as the “Authority.” If the Authority decides to admit a petition for
consideration, it usually orders publication of a public notice and appoints a Case Officer
from NEPRA staff.
STEP 3: PUBLIC COMMUNICATION
The salient features of the petition are generally advertised in leading newspapers of the
country and a date for a public hearing is fixed. The advertisement also solicits comments
and intervention requests from interested parties and includes a notice that a copy of the
petition can be obtained from the NEPRA offices for a token fee. In addition, most petitions
are uploaded to the NEPRA website. Copies of the petition are also sent to important
stakeholders, including power sector companies, government departments, industry
representatives, chambers of commerce, etc.
STEP 4: PUBLIC HEARING
Any “interested person” may file leave to intervene with respect to a tariff petition, upon
payment of a fee to NEPRA. Public hearings are then held on the tariff petition. Most of the
public hearings are held at NEPRA head office in Islamabad, but occasionally hearings may
also be held in the city in which the relevant DISCO’s headquarter is based. During the
public hearing, the petitioner DISCO (through its representatives) pleads its case, giving
reasons for the tariff requested and explaining how the tariff has been calculated. The
petitioner also gives its response to the issues raised by the Case Officer, commentators,
and interveners.
STEP 5: RESOLUTION OF ISSUES
At the conclusion of the public hearing, the Authority announces a date for evidence closure
and all stakeholders may submit evidence on or before that date. In most cases, the Case
Officer also sends an information directive to the petitioner requesting information deemed
necessary. The Case Officer also may hold subsequent meetings with the petitioner’s
representatives to seek further clarification and explanation of issues.
STEP 6: DECISION TIMELINE
According to NEPRA’s rules, the maximum time period available to NEPRA for issuing a
tariff determination is four months from the date of the tariff petition filing. The Authority may
extend the aforesaid four months period by one month, only for causes beyond its control
and subject to a maximum of four such extensions. The reasons for such an extension must